Privacy Notice

This privacy notice (“Notice”) describes how your personal information (“PI”) is used by The University of the Witwatersrand (the "University") as a result of your engagement with us – including, what PI we collect, how we use it, and why. This Notice applies to PI gathered from, amongst others, the University’s current and former students, employees, research participants, alumni, contractors or service providers and donors.

The University must collect and process certain PI about you when you engage with the University, to enable us to manage our relationship with you and run the University. This PI will come directly from you or from other sources, including external sources. The University’s collection and processing of your PI is subject to all applicable laws and to the University’s Protection of Personal Information Compliance Framework.

What PI the University Collects

Should you engage with the University, whether as an employee, student, donor or otherwise, the University may collect PI about you. This PI includes, amongst others, information relating to your education, your financial or employment history, your contact details, any references, and other private or confidential information.

How the University Collects Your PI

In most cases, the University collects PI directly from you during the application or recruitment process, or from our interactions with you during your enrolment or employment with the University, or when you conduct business or make enquiries with the University. In some cases we may collect PI about you from sources other than yourself, including from references that you provide to the University, from previous educational establishments and from public records.

Purpose for which Your PI is Being Collected

The University collects your PI for various purposes. Some of these purposes and the ways in which the University uses your PI include the following:

To pursue the University’s legitimate business interests;
To meet our obligations as an educational institute and employer;
To provide teaching, learning and research;
To manage your use of and access to the University’s facilities;
To operate security, disciplinary, compliant and quality assurance processes and arrangements;
To comply with our contractual obligations to you and to others;
To comply with legal requirements and obligations imposed on us by law;
If necessary, in order to pursue your own vital interests (e.g., medical or other emergency response); and
To ensure that our IT facilities, networks and communication systems are secure.

Whether the supply of your PI is Voluntary or Mandatory

When you engage with the University, we will need to use your PI for the University’s administrative, educational, or other business-related purposes. Without processing your PI, it will not be possible for the University to fulfill its obligations, whether under contract with you or in terms of the University’s statutory obligations. Your consent is not required where the University is required to process your PI to fulfil its obligations under contract with you or in terms of the other justifications prescribed by the Protection of Personal Information Act of 2013. Nonetheless, withholding your PI may obstruct or prevent the University from being able to render services to you and carry out its obligations, under contract or in law. For a complete list of all laws that are applicable to the University, some of which authorise or require the collection of PI, please refer to the University’s PAIA Manual.

The University’s Collection and Processing of Special Personal Information

In some cases, the University will also collect and process special personal information (“SPI”) about you. SPI includes information related to your religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometrics or criminal behaviour.

We collect SPI for specific purposes, such as:

Collecting health related information to provide health benefits or accommodate a disability;
Monitoring safety, industrial hygiene and exposures in our facilities;
Collecting diversity-related information (such as gender and race) to comply with legal obligations and internal policies relating to diversity and non-discrimination; or
Collecting biometric information for security purposes or to facilitate your access to the University’s systems.

Generally, the University’s collection and processing of such SPI will be conducted only with your voluntary consent, upon disclosure of the purposes for which such SPI is processed. However, your SPI will also be processed if the University is required to do so to comply with obligations imposed on it by law, or for making or defending legal claims.

Transfer and Sharing of PI

Access to SPI is limited to those who have a need to know such information, for the purposes described in this Notice, including functional support in the University’s HR, IT, Legal and Finance departments.

In some cases, PI is shared with third parties such as vendors, contractors and other University service providers, external examiners and assessors, and external individuals that participate on the University’s panels, committees or other structures, as well as with legal and regulatory authorities. In certain instances, these third parties are entities or individuals resident in countries outside of South Africa or forming part of international organisations.

In all instances, the sharing and transfer of your PI is necessary in order to meet our contractual obligations with you, or on other lawful and recognised grounds, and is carried out with appropriate safeguards in place to ensure the confidentiality and security of your PI.

Your Rights to Your PI

As a data subject you have a number of rights in relation to your PI. You can, amongst others:

require the University to confirm whether or not we hold any of your PI;
require us to amend incorrect or incomplete PI;
object to the, or require the University to stop, processing your PI, for example where the processing of your PI is no longer necessary;
require us to erase your PI;
where our processing of your PI is based solely on your consent, you may withdraw that consent; or
receive from us the PI we hold about you, which you have provided to us, including for the purpose of you transmitting that PI to another responsible party.

Please note that the above rights are not absolute, and the University may be entitled to refuse requests where exceptions apply.

For further information, or if you wish to exercise any of these rights, or if you have a complaint about the way you believe your PI is being processed, in the first instance, please contact the University’s Deputy Information Officer, the details of which are set out in the University’s PAIA Manual or email: Carol.Crosley@wits.ac.za.

If you have a complaint and you remain dissatisfied with how your complaint has been dealt with you may take your complaint to the Information Regulator who can be contacted at inforeg@justice.gov.za.

Changes to this Privacy Notice

The University has the right to update this Notice.

Contacting the University

Questions, requests and inquiries concerning this Notice, and the information set out in this Notice, may be directed to the University’s Deputy Information Officer: Carol Crosley at Carol.Crosley@wits.ac.za

Privacy Notice

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